To comply with the Russian President's Decree on 1 November 2018 the Federal Government passed Resolution No. 1300 implementing Russian President's Decree No. 592 of 22 October 2018 (the 'Resolution').

The Resolution introduces special economic sanctions on 322 Ukrainian nationals and 68 businesses somehow related to Ukraine and controlled by those individuals. The individuals and legal entities sanctioned include judges, Members of the Ukrainian Parliament, prominent Ukrainian entrepreneurs, officers of the Ukrainian Presidential Administration, heads of Ukrainian executive authorities and managers of large Ukrainian companies, and legal entities controlled by high-profile Ukrainian businesspersons.

The above-mentioned Resolution prescribes that such special economic measures should include the blocking/freezing of non-cash money, uncertificated securities and assets in the Russian Federation and the prohibition of transfers of funds/capital outflows from the Russian Federation. The Resolution comes into effect from the date of its publication.

It should be noted that, taking into account certain aspects of sanctions law of other countries and that of Russia, the persons who have found themselves on the sanctions lists could face other negative consequences in addition to the restrictions set forth above.

First, certain Russian ministries and authorities may also take measures to impose restrictions on the activities of the persons sanctioned.

Second, the restrictions could affect not only assets based in Russia but also assets that are temporarily managed by, or kept with third countries or financial institutions owned or controlled by Russian entities.

Third, counterparties of the persons sanctioned could consider the introduced sanctions as an additional force-majeure circumstance when executing certain contracts.